PRIVACY POLICY

Sappaya International Limited, with registered office at 4th Floor Exchange House, 54-58 Athol Street, Douglas, Isle of Man, IM1, 1JD (“Sappaya”) operates the website sappaya.com. Sappaya is fully committed to protecting the security and ensuring the right to privacy of each individual using this website (“Site”).

This is the privacy policy (“Privacy Policy”) of Sappaya which applies to your interaction with Sappaya by using the Site. It explains which Personal Information (as defined below) is collected, how we use Personal Information that we collect, receive and store for each visitor of sappaya.com. Other privacy policies may also apply in addition to the terms of this Privacy Policy depending upon your relationship with Sappaya (for instance as client/merchant, as user of the Sappaya portal and/or as a customer of an Sappaya merchant). Reference is made to the other privacy policies available through the Site.

Information

Personal Information. As part of the possibilities to receive more information or send a contact request via our Site, we collect your Personal Information, which can be completed given at your discretion. “Personal Information” means any information that may be used to personally identify an individual, including, but not limited to, a first and last name, an email address, a home or other physical address, or other contact information. The information you provide allows us to provide an efficient service to you and helps us improve our level of service to better meet your needs.

Legal basis: Consent

In completing the contact request form on or submitting a career application through the Site, you will be requested to confirm your acceptance of this Privacy Policy. By doing so, you shall consent to the terms of herein and to Sappaya processing of Personal Information for the purposes set forth herein. If after you opt-in, you change your mind, you may withdraw your consent for us to contact you and/or for the continued collection, use or disclosure of your information, at any time at the contact details referenced at the bottom of this Privacy Policy. Any such withdrawal will not affect the legal basis on which we have processed your Personal Information before your withdrawal.

You are not obliged to provide any of the Personal Information and/or to complete the contact request form. If you choose not to, we will not be able to contact you regarding our services.

Types of information we collect

Contact Details. When you fill in the contact request form on or submit a career application through the Site, we will (i) request your full name, email address, phone number and any other contact information; and (ii) when submitting a career application, also request a copy of your resume and a cover letter (which may include any further personal data from you like date of birth or any other personal data).

We may use this information (i) to contact you; (ii) to provide further information about our services; (iii) if you have submitted a career application through the Site, to provide further information on potential employment opportunities, to review your application and/or to conduct candidate screening. During any such contact, we may request further Personal Information if relevant for the particular situation, to enable us to process your questions and answer your requests.

Log Files. When you browse the Site, we automatically receive your computer’s Internet Protocol (IP) addresses, type of browser, type of device used, information about your device’s operating system, Internet Service Provider (ISP), and any other (location) information (about your device or browsing activity) your browser may send to us. We may use this information to analyze and improve accessibility and compatibility of the site, trends, user experience, and gather demographic and statistical information to monitor our services and make it better.

Cookies. In order to ensure that your visit to our Site is smooth, reliable and useful, some of our Site pages utilize “cookies”. A “cookie” may be used, for example, to collect information about Site activity such as but not limited to store information about your session (referrer, landing page, etc), and record number of visits. Most browsers allow you to control cookies, including whether or not to accept them and how to remove them. How to do that depends upon the browser you use. Visit this page to learn more: https://www.youronlinechoices.com. Doing so may limit the functionality we can provide when you visit our Site.

We do not collect and process any Personal Information for other purposes than as described in this Privacy Policy. If we do intend to process your Personal information for any other purpose for which we initially collected it from you, we will provide you all further relevant information on that purpose and obtain your consent.

How do we use personal information

All Personal information that you submit or we collect may be used in the following but not limited to:

Improve our Site and contact you about and/or sell certain products or services.

Use your registered external address, email address, mobile or telephone number to send you updates, newsletter, news, promotions and/or marketing material regarding the Site and our products and services. Or contact you in response to a “contact us” or “chat with us” request.

We won’t share your Personal Information with third parties without obtaining your prior consent, unless the transfer is necessary for maintaining our relationship with you, in which case you will be informed before such information is shared (see section Third-party services).

Your Personal Information may be transferred outside the European Economic Area, depending upon its purpose of processing. These third-countries are, under applicable data protection legislation, either considered to be a country that ensures an adequate level of protection or we will ensure that appropriate safeguards are put in place to protection your Personal Information and your continued availability of your rights under applicable data protection legislation. See further the section Third-party services).

Security

We will process any received Personal Information in accordance with the requirements of applicable data protection legislation, including the upcoming European General Data Protection Regulation.

To protect your personal information, we have implemented adequate technical and organizational measures and follow industry best practices to make sure it is not inappropriately lost, misused, accessed, disclosed, altered or destroyed. The data will be stored on secured servers of us or a third party to whom we have contracted this.

Data retention

The Personal Information will not be stored longer than necessary for the provision of our service and for as long as you use the related feature of the Site or as required by applicable law, unless you choose to delete it. Please note that some or all of the data collected may be required in order for the Site to function properly and we may be required to retain certain information by law.

Third-party services

We may use third parties for the hosting of our servers or other IT related services. These parties (such as Amazon Web Services) are based within the European Economic Area. We have made arrangements with such parties to ensure the proper security of your Personal Information in compliance with applicable data protection legislation.

Further, in the event of any contact request through our Site, your data will be transferred to a marketing automation provider, which has servers based in the US. The provider MailChimp is self-certified under the EU-U.S. Privacy Shield Framework, which is considered to ensures an adequate level of protection

For any recruitment processes, your career application may be shared within our group, with offices outside the EU. We ensure that appropriate safeguards are set in place to protect your Personal Information and that your rights and effective legal remedies remain available to you.

In any case, when the data transfer is not necessary for the proper provision of the relevant service, we will inform you of the purpose of processing and the identity of the potential third parties so that you may permit or refuse the transfer depending on its purpose. In general, the third-party providers used by us will only collect, use and disclose your information to the extent necessary to allow them to perform the services they provide to us.

Your rights

You can always request insight in your Personal Information held by us and request rectification or erasure (the “right to be forgotten”) of such Personal information. Further, you retain the right to request restriction of processing (if for instance you objected to our processing or you contest the accuracy of the Personal Information) or to object to the processing as laid down in this Privacy Policy. The objection may relate to particular processing purposes such as direct marketing or all purposes.

Finally, you may also contact us and exercise your right to data portability. This means you may receive your Personal Information which you have provided to us, giving you the right to transmit this to a third party, provided that the processing by us has been carried out by automated means and such transfer is technically feasible.

You can send an email to the email address as indicated below. If special personal circumstances justify objection of the handling of your Personal Data, please let us know via email, providing the reasons therefore. In the event you choose to withdraw your consent to process your Personal Information, we will no longer be able to contact you.

We will inform you about any rectification or erasure of your Personal Information or restriction of processing carried out pursuant to your request. In the event we do not conform to your request, for justifiable reasons, we will inform you without delay and clarify the reasons for not taking action. You may then exercise your rights under the next section. Any objection by you to our processing for direct marketing purposes shall be complied with at all times.

Right to lodge a complaint

Besides any other remedies given by you under law, you will have the right to lodge a complaint with the data protection authorities in your country or in Isle of Man, if you feel that our processing of your Personal Information infringes applicable data protection legislation. Please visit the website of the data protection authorities in your country to obtain more information on how the complaint procedures work.

Children’s privacy

The Site is not structured to offer its products and services or collect information to individuals under the age of 18.

Links

When you click on links on our Site, they may direct you away from our Site. We are not responsible and expressly exclude ourselves from liability for any damages which may be caused by the privacy practices of other sites and encourage you to read their privacy statements prior to use.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time, at our sole discretion, so please review it frequently. Changes and clarifications will take effect immediately upon their posting on the Site. If we make material changes to this Privacy Policy, we provide a notification herein that the same has been updated, so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we use and/or disclose it.

If our company is acquired or merged with another company, your information may be transferred to the new owners so that we may continue the services we offer.

Questions and contact information

If you would like to: access, correct, amend or delete any personal information we have about you, register a complaint, or simply want more information, contact us at enquiries@sappaya.com or mailing us at: 4th Floor Exchange House, 54-58 Athol Street, Douglas, Isle of Man, IM1, 1JD.